Annex 3
WORKING TIME DIRECTIVE
In the UK, the major cost of implementation
of the proposals in their present form—with seriously limited
flexibility—will be substantial. A number of individual
case studies are appended to this submission. In general, FTA
envisages:
I. Costs arising from the need to employ
additional drivers, coupled with recruitment difficulties in this
area—the skills shortage in terms of qualified and experienced
hgv drivers is a longstanding problem in the UK. Increased employment
costs will not be balanced out by the inevitable reductions in
wages which many existing drivers will experience as a direct
consequence of their hours of work being reduced.
II. Costs arising from the need to deploy
additional vehicles to maintain existing schedules. At its simplest,
a 10 per cent reduction in available hours does not mean a corresponding
10 per cent increase in the fleet is needed. If an operation cannot
be encompassed within the new limits, up to a doubling of an existing
fleet could be necessary. This figure may well be at the other
extreme compared to the Commission's modest assertion that "limited"
investment in new vehicles may be necessary, but there is no doubt
that the impact in this area will be substantial. What is certain
is that many companies operating in an industry where margins
are already tight and where every effort is made on economic and
environmental grounds to reduce to number of vehicles in use will
be faced with the clear and unwelcome prospect of having to substantially
invest in new equipment.
III. Costs arising from the indirect implications
of these proposals will range from the administration costs involved
in rearranging sophisticated schedules to the effects of less
efficient operations previously undertaken at night have to be
carried out during the day.
The Commission's proposals would result in substantial
cost increase resulting from reductions in driver and vehicle
productivity. Case histories show figures ranging 5 to 20 per
cent. Maintenance of driver earnings at current levels would require
up to a 35 per cent increase in wage costs, coupled with loss
of night work bonuses and other earning opportunities.
The economic impact of the Commission's proposals
has been seriously underestimated—it will be negative and
substantial.
FREIGHT TRANSPORT ASSOCIATION
Working time—the European Commission's
Proposals for Road Transport
CASE HISTORIES
1. A major distribution company in the drinks
industry
The company's average working weeks are currently
55 hours for day shift drivers and 60 hours for night shift. The
loss of seven hours per man in the day shift equates to two deliveries
per day, resulting in an increase of six vehicles/drivers over
the current fleet of 38. The total cost implication for the company,
including anticipated rate increases by sub-contractors, would
exceed £500,000 per annum.
The impact in night shift operations would be
particularly serious; current schedules are based on eight hours
driving plus associated work such as changing trailers. An eight
hour limit would increase the resources needed by over 50 per
cent, with cost implications of around £150,000 per annum.
In the long term, the depot locations would have to be reassessed.
The proposed caps would pose problems, particularly
in terms of the seasonal peaks in October to December.
2. A national supermarket chain
The company's distribution operations are based
on a network of 14 depots, 1,000 drivers and 800+ vehicles. The
average working week varies from depot to depot, between 52 and
58 hours. A 48 hour average working week would result in reduced
pay for existing drivers coupled with the need to recruit on a
permanent or agency basis 100 more drivers.
Up to 300 drivers currently work on night shift,
and an eight hour average limit would result in increased nights
out, some double manning, more drivers working at night and additional
vehicles. Additional costs could be in excess of £1 million.
3. A multi-national manufacturer/distributor
of soft drinks
The working week limitation would give rise
to a 10 per cent increase in vehicle operating costs, resulting
from a reduction in the current average working week of 53.5 hours.
Fourteen additional drivers and vehicles would be needed to maintain
schedules, whilst the night work limits would impact on bulk movements
by sub-contracted hauliers.
4. A major brewer
Drivers present work between 45 and 50 hours
per week. There would be problems at seasonal peak trading periods
which would be eased by an ability to average over a 12 month
period.
Night work limits would impact on the current
double or even triple shifting of the primary distribution fleet.
An eight hour average limit could necessitate a complete reappraisal
of existing schedules since existing trips would not be achievable.
The overall cost implication would be around 20 per cent. The
10 hour cap would conflict with the need to use the maximum period
available under the driver' hours rules for some shifts.
Some night work would move to days, with reduced
efficiency and increased costs. The company points to evidence
of some drivers on day work experiencing stress to the
point of sick leave due to traffic congestion. Reductions in night
work will limit opportunities to switch drivers and thus afford
some relief.
5. A regional producer/supplier of roadstone
aggregates
In theory, schedules could be accommodated within
a 48 hours limit. In reality delays at customers' premises result
in 11/12 hour days being the norm, and up to 15 hours being needed
on occasions. The end result would be a need for eight additional
drivers, leading to a 20 per cent (£178,000) increase in
employment costs.
Night working is necessary in connection with
motorway repairs etc. The company does not use dedicated night
drivers. An eight hour average limit would mean increased switching
between days and nights and a need for more drivers as a consequence.
Night shift costs could increase by around 30 per cent.
6. A furniture manufacturing company
Drivers presently work an average 55 hour week;
most factors (numbers of vehicles/drivers etc.) would increase
by 10-15 per cent as a result of a reduction to an average 48
hours, with cost increases of the same order.
Night drivers currently work between nine and
10 hours per shift. The company's depots cannot be serviced on
the basis of an eight hour average schedule, and cost implications
of +£200 per individual shift would result from the necessary
introduction of double manning and changeover points.
7. A national parcels distribution company
The company introduced a new structure in 1999
based on 240 aggregated hours per four week period. The effective
reduction from 60 to 48 hours per week would give rise to cost
increases of around £965,000 per annum—resulting from
the need to take on 40 additional drivers, 25 new tractor units
and 35 trailers. The 60 hours cap would pose problems for rotating
shifts.
The locations of many depots require one-way
journey times from the company's hubs of four hours+. Driving
time alone will thus exceed the eight hours limit without taking
into account other necessary work. The result is that all journeys
involving more than 8 hours working time would require a doubling
of resources to allow changeovers to operate. Increased costs
of almost £2.7 million would result.
8. A manufacturer of conservatory systems
The company's drivers currently work an average
55 hour working week. They estimate that a 48 hours average week
would require a 25-30 per cent increase in drivers which, coupled
with porportionate increases in vehicles/fuel costs/wages etc
would result in an overall cost increase of 40 per cent. Similar
considerations would apply to night shift operations—the
imposition of an average eight hours limit would result in cost
increases of around 30 per cent.
9. A major oil distribution company
The company estimates that a 7 per cent increase
in vehicles and drivers, coupled with a 5 per cent increase in
costs, would result from a reduction in the average working week
from the current figure 52.5 to 48 hours. The limits on night
work would be totally incompatible with the current practice of
triple-shifting vehicles; drivers work a night shift for one week
in three, but in future two drivers would have to work nights
for each one at present. A 5 per cent increase in vehicles and
drivers would be needed. The 60 hours cap would result in some
transfer of movements to daytime.
10. A major manufacturer of breakfast cereals
Although day shift operations would be largely
unaffected by the proposed 48 hour limit, a limit of eight hours
night work with a 10 hour cap would result in the company's night
trunking changeover-based operation being substituted by a day
time schedule requiring two days driving.
11. A national cereals/milling company
The company's multi-drop operations are based
on a 47 hour average week, although bulk and trunking operations
involve a 55 hour average. Night shift drivers usually work a
10 hour shift. They estimate additional costs arising from the
proposed limits in these areas to be in the region of 5-6 per
cent and emphasise that the night work limits would preclude the
use of present schedules whilst the 48 hour week would necessitate
increased resources in all areas to maintain service to their
customers.
12. A major logistics company
The company employs some 4,500 drivers, and
the impact of these proposals will vary on a sectoral basis. For
example, in the retail sector 4 per cent increases in drivers
and equipment are seen as a minimum requirement to meet the weekly
work limit, with night work limits inhibiting flexibility. In
the manufacturing sector, a reduction from the current average
58.3 hour week would result in a move to a 20 per cent (160) increase
in numbers. If wage levels were maintained, extra costs of £3.6
million would result. Existing schedules could not be accommodated
within the proposed night work limits, and costs of up to £5
million would be involved based on a need for additional vehicles,
drivers and depots.
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